Tag Archives: ITAR

By Daniel Pickard, Laura El-Sabaawi, Jack Shane and Lori Scheetz on May 16, 2018 Posted in Export ControlsYesterday, the Trump Administration announced a plan to transfer control over the export of small arms from the U.S. Department of State’s International Traffic in Arms Regulations (ITAR) to the typically less-stringent U.S. Department of Commerce’s Export Administration Regulations (EAR). The shift will affect U.S. small arms exports, including non-automatic and semi-automatic firearms up to .50 caliber,… Continue Reading

By Lori Scheetz on February 5, 2018 Posted in Export ControlsLast week, the Department of State’s Directorate of Defense Trade Controls (DDTC) announced that it has added South Sudan to its list of prohibited countries under the U.S. International Traffic in Arms Regulations (ITAR). This designation means that with certain limited exceptions, export licenses for ITAR-controlled munitions items and related services are now subject to… Continue Reading

By Lori Scheetz on December 12, 2016 Posted in Export ControlsGet ready. On December 31, the Department of State, Directorate of Defense Trade Controls’ (DDTC) and the Department of Commerce, Bureau of Industry and Security’s (BIS) final rules revising the export controls on fire control, laser, imaging, and guidance equipment are set to go into effect. These rules are part of the Administration’s Export Control… Continue Reading

By Lori Scheetz on October 3, 2016 Posted in Export ControlsAs detailed in a prior post, the Department of State’s Directorate of Defense Trade Controls (DDTC) recently announced significant changes to its policies on exports of munitions items to Côte d’Ivoire (Ivory Coast), Liberia, Sri Lanka, and Vietnam. Last Thursday, DDTC codified these changes in the U.S. International Traffic in Arms Regulations (ITAR), eliminating any… Continue Reading

By Lori Scheetz on August 29, 2016 Posted in Export ControlsExactly a year after their last round of proposed rules, the Department of Commerce’s Bureau of Industry and Security (BIS) and Department of State’s Directorate of Defense Trade Controls (DDTC) published their much-anticipated final definitions rules. These rules revise certain key terms in the Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR).… Continue Reading

By Lori Scheetz on August 26, 2016 Posted in Export ControlsLast week, the State Department’s Directorate of Defense Trade Controls (DDTC) and the Commerce Department’s Bureau of Industry and Security (BIS) harmonized the destination control statements (DCS) required for exports of certain items from the United States. The new rules, which took more than one year to finalize, ease the burden on exporters by requiring… Continue Reading

By Lori Scheetz on July 28, 2016 Posted in Export ControlsToday, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published final rules to amend U.S. export controls on toxicological agents and associated equipment, along with directed energy weapons and related items. Effective December 31, 2016, the final rules revise Categories… Continue Reading

By Lori Scheetz on June 10, 2016 Posted in Export ControlsThe Department of State’s Directorate of Defense Trade Controls (DDTC) recently announced several changes to the U.S. International Traffic in Arms Regulations (ITAR), including to its country policies and embargoes and its civil penalties. These new policies may require corresponding changes to your company’s export compliance program and ITAR risk assessment analyses. First let’s start… Continue Reading

By Lori Scheetz on February 22, 2016 Posted in Export ControlsOn February 19, the Department of State’s Directorate of Defense Trade Controls (DDTC) and the Department of Commerce’s Bureau of Industry and Security (BIS) issued new proposed rules to revise the export controls on fire control, laser, imaging, and guidance and control equipment. These new proposals are part of the Administration’s Export Control Reform Initiative… Continue Reading

By Laura El-Sabaawi and Daniel Pickard on February 17, 2016 Posted in Export ControlsThe D.C. District Court has dismissed a challenge to the Department of State’s application of the International Traffic Arms Regulations’ (ITAR) brokering provisions to attorneys. Notably, the challenge was filed by international trade law firm Matthew A. Goldstein, PLLC on its own behalf, regarding the application of the brokering provisions to legal services provided to… Continue Reading

By Lori Scheetz on February 17, 2016 Posted in Export ControlsLast week, the Department of State’s Directorate of Defense Trade Controls (DDTC) and the Department of Commerce’s Bureau of Industry and Security (BIS) published proposed rules (available here and here) that would modify the export controls on military aircraft, military gas turbine engines, and related items. The proposed adjustments are part of the U.S. government’s… Continue Reading

By Lori Scheetz on June 30, 2015 Posted in Export ControlsOn June 17, 2015, the Department of State’s Directorate of Defense Trade Controls (DDTC) and the Department of Commerce’s Bureau of Industry and Security (BIS) published proposed rules to amend U.S. export controls on toxicological agents and associated equipment and directed energy weapons. The proposed rules mark yet another important step in the President’s Export… Continue Reading

By Lori Scheetz on June 23, 2015 Posted in Export ControlsOn June 3, 2015, the Department of Commerce’s Bureau of Industry and Security (BIS) and Department of State’s Directorate of Defense Trade Controls (DDTC) published much-anticipated proposed rules, updating key terms in the Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR). The proposed rules address a host of important definitions and attempt… Continue Reading

By Lori Scheetz on June 3, 2015 Posted in Export ControlsAs part of a flurry of recent proposed and final amendments to U.S. export controls regulations, on May 26, 2015, the Department of State’s Directorate of Defense Trade Controls (DDTC) issued a proposed rule clarifying the registration and licensing requirements under the International Traffic in Arms Regulations (ITAR) for U.S. persons employed by foreign companies.… Continue Reading

By Lori Scheetz on May 5, 2015 Posted in Export ControlsToday, the Department of State issued a proposed rule to amend the International Traffic in Arms Regulations (ITAR) to revise Category XII of the U.S. Munitions List (USML). The Department of Commerce issued a companion proposed rule to amend the Export Administration Regulations (EAR). These proposed rules are part of the Administration’s ongoing Export Control… Continue Reading

By Lori Scheetz on December 30, 2014 Posted in Export ControlsToday is the effective date of the Department of State’s final rule (with corrections available here) and the Department of Commerce’s final rule revising the export controls applicable to electronics. The new rules shift control of many electronics from the State Department’s International Traffic in Arms Regulations (ITAR) to the Commerce Department’s Export Administration Regulations… Continue Reading

By Laura El-Sabaawi and Lori Scheetz on November 12, 2014 Posted in Export ControlsThe U.S. Department of State has revised the International Traffic in Arms Regulations (ITAR) to change its longstanding policy on exports of certain lethal defense articles to Vietnam. Since the end of the Vietnam War, the State Department has imposed a presumptive policy of denial with regard to all such exports – i.e., the agency… Continue Reading

By Lori Scheetz on November 10, 2014 Posted in Export ControlsToday, the Department of State’s final rule (with corrections available here) and the Department of Commerce’s final rule revising the export controls applicable to satellites and related parts, components, software, technology, and services became effective. The agencies published interim final rules detailing the changes in May 2014. This is long-awaited and welcome news to the… Continue Reading

By Lori Scheetz on October 20, 2014 Posted in Export ControlsUnder the U.S. International Traffic in Arms Regulations (ITAR), training on a defense article is a defense service generally covered by the U.S. Munitions List (USML) category in which the defense article is enumerated. In other words, training on a firearm controlled by Category I of the USML is also covered under Category I.… Continue Reading

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